YOU HELPED US GET OUR MESSAGE TO TCEQ and we thank you!
HERE IS WERE WE STAND ON THE PENDING WASTEWATER PERMIT::
On the April 22nd TCEQ Commissioners Agenda Meeting
the 3 Commissioners decided that
Friends of Hondo Canyon has legal standing to protest the wastewater permit.
TCEQ Commissioners identified 8 points for the judge to hear
1. Is the permit protective of water quality and antidegradation policy?
2. Is the permit protective of groundwater and wells?
3. Is location of outfall adequately defined by the application/permit?
4. Was there applicable public notification of the permit request?
5. Is the permit protective of health of requesters, their families and wildlife?
6. Does the approval consider the compliance of the applicant?
7. Is there a need for the permit to be granted?
8. Is the site/suitability/odor related to the permit a concern not addressed in the application?
The Commissioners suggested we be referred to ADR = Alternative Dispute Resolution. We have until mid August to negotiate with the Torns to resolve these issues before going to court.
SEPTEMBER 28, 2020 is our SOAH HEARING DATE
We respect the legal process of mediation and hope that RR 417 proceeds to listen and respond to the issues we have raised. We are all neighbors, and we welcome their camp but do not welcome wastewater discharge into our creek and waste of groundwater, particularly during drought.
On the April 22nd TCEQ Commissioners Agenda Meeting
the 3 Commissioners decided that
Friends of Hondo Canyon has legal standing to protest the wastewater permit.
TCEQ Commissioners identified 8 points for the judge to hear
1. Is the permit protective of water quality and antidegradation policy?
2. Is the permit protective of groundwater and wells?
3. Is location of outfall adequately defined by the application/permit?
4. Was there applicable public notification of the permit request?
5. Is the permit protective of health of requesters, their families and wildlife?
6. Does the approval consider the compliance of the applicant?
7. Is there a need for the permit to be granted?
8. Is the site/suitability/odor related to the permit a concern not addressed in the application?
The Commissioners suggested we be referred to ADR = Alternative Dispute Resolution. We have until mid August to negotiate with the Torns to resolve these issues before going to court.
SEPTEMBER 28, 2020 is our SOAH HEARING DATE
We respect the legal process of mediation and hope that RR 417 proceeds to listen and respond to the issues we have raised. We are all neighbors, and we welcome their camp but do not welcome wastewater discharge into our creek and waste of groundwater, particularly during drought.
Protect Our Future!
Protect the Last Clean Water in Texas
In the first phase of the TCEQ protest process, the public can comment directly to TCEQ their concerns regarding pending permits. We have completed this phase for the wastewater permit, and will soon complete this phase for the water rights permit. The Executive Director's office at TCEQ reviews the public's comments and based on their relative merit, either decides outright to reject the permit, or recommends that the three TCEQ Commissioners who oversee permitting turn the process to a legal proceeding (Contested Case Hearing) run by the State Office of Administrative Hearings (SOAH).
In the second phase of the TCEQ process, we cross a new threshold: negotiations now benefit from legal council. We have a SOAH date for TCEQ Draft Permit #WQ0015713001 Monday September 28, 2020 (location TBA).
We begin a fundraising campaign
WIN-WIN FOR WATER
Please donate to our cause!
The Battle to Keep Commissioners & Hondo Creek Pristine
The Friends of Hondo Canyon have come together to fight a legal battle to protect Commissioners’ Creek and upper Hondo Creek, spring-fed headwater streams with pristine water quality located in the upper Nueces River Basin. They are some of the last remaining classified stream units in Texas with no documented pollution concerns or impairments.
We are protesting wastewater permit No WQ0015713001, which has been proposed to the Texas Commission on Environmental Quality (TCEQ) by RR 417 LLC, a company that has plans to develop a for-profit Christian summer camp on its land in Tarpley, Texas. Sam and Chris Torn own the Company that has proposed the wastewater permit. If approved by the TCEQ, this proposed Wastewater Permit No WQ0015713001 will allow the Torns, who also own a popular Christian Boys Summer Camp in Arkansas called "Camp Ozark", to build an activated sludge wastewater treatment plant on the edge of their property in Tarpley that will discharge up to 49,000 gallons of treated waste water directly into Commissioner’s Creek. The Torns have stated in the draft permit that they will be applying for a water reuse permit, and will only discharge up to 25% of the effluent into the creek; however ANY discharge, no matter how small, sets a precedent for more permits to be approved. We simply cannot allow this to happen. Below we have listed reasons why. |
Creek & Aquifer Contamination
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This permit, if approved, will be a game changer for our creek. Commissioner & Hondo Creek has NEVER received effluent. There were 7 other TCEQ wastewater permits that WQ0015713001 was being compared to. This permit is NOT the same. The other 7 permits are for bigger creeks/rivers that have already receive wastewater effluent — and again — our creek has NEVER received effluent.
One of the 7 permits has recently been changed to a Texas Land Application Permit - A big win for the Honey Creek State Natural Area that was poised to receive the effluent. We must remain hopeful that the Tarpley Camp developers also see the benefits of changing their application to a zero discharge system. If they don't, the concentration of nutrient in treated wastewater will be hundreds, to thousands, of times greater than current background levels in these creeks. Even the best, most highly treated wastewater, can be expected to “fertilize” a nutrient starved headwater stream, causing excessive algae growth and interrupting clarity, temperature, oxygen and aquatic life cycles. And importantly, after Commissioner’s Creek meets the Hondo, the Hondo Creek goes underground and flows into the Edward’s Aquifer Recharge Zone contributing its water to the Edward’s Aquifer. Accidental contamination is a significant issue. In addition, the removal of pharmaceuticals and personal care products from the wastewater is absolutely impossible with the technology that is being proposed to use to treat the waste water. Hormones and chemicals will, without fail, pollute our creek and empty into the Edwards Aquifer which is a source of drinking water for over 2 million people in the south Texas region. Alternative Options are Readily AvailiableAlternatives exist! A Zero Discharge Permit would allow the disposal of treated waste water by irrigation, instead of discharge to a stream. Other camps and towns in the upper Nueces basin utilize irrigation/land application for disposal of treated wastewater. The Cornerstone Church Conference/Retreat Center at 12125 FM 470 uses a zero discharge system for a similar volume of use. These alternatives are no more costly; they permit native soil to cleanse treated wastewater prior to its entry into groundwater and stream beds. We ask RR417 LLC to do the right thing for us and for our land! Don’t pollute our creeks! We must come together as a community to stop the approval of this permit.
Air PollutionThe proposal locates the package plant at the very most downstream edge of their property. Required aeration for adequate microbial action will release H2S gas into the atmosphere, which has a very foul smell. The gas will also be carried by the wind downstream from this property. The neighbors will suffer consequences from the air pollution.
Drought & FloodDischarging effluent into a creek bed during drought will cause the allowable bacterial content of discharge water to multiply.
In the many years the members of Friends of Hondo Canyon have owned property in Tarpley, we have seen the effects of drought on the land and on the wildlife that depend upon the creek for drinking water. Commissioners creek can completely dry up during times of drought; a few spring fed puddles appear and these conditions have lasted for as long as a year. Effluent discharge is certainly not going to keep our creek clean in a drought. In addition to droughts, the other major characteristic of the central Texas corridor is flash floods. The founder of Friends of Hondo Canyon built a bridge over Commissioners Creek for ease of access to her property. In the past 15 years, the creek has risen 12-15 feet – a height 3 feet over her bridge on 5 occasions; this magnitude of rain will indeed cause raw sewage contamination of our creek. Location of Proposed Wastewater Plant |
The owners have chosen to locate their proposed wastewater system at the western most border of their property – hence, they will not experience any negative consequences from their purposeful impact of the environment. If this wastewater system fails – by poor design or by an act of nature, the owners will suffer no consequences to their riparian area, as the discharge will float downstream. This is unacceptable. If TCEQ does permit this plan, at the very least the site of the sewage treatment must be moved to the most eastern border of their property, so these landowners will suffer, along with their neighbors, the consequences of any accidental contamination of our air or our groundwater from their system.
Power Outages
Power outages happen. And they happen all the time. In Wylie, Texas, about 28,000 gallons of wastewater spilled at the North Texas Municipal Water District site, which then flowed into nearby Lake Lavon according to a report published by a local CBS Dallas news station. This happened during a heavy thunderstorm and power outage. The wastewater treatment plant failed because of the power outage!
The only way we can fight this is to join together. Our pristine creeks are worth the fight."
- Margo Denke, Founder of Friends of Hondo Canyon
We Need Your Help
There are a few things you can do to help us fight this battle.
1. WRITE THE ELECTED OFFICIALS
We have letters from our State Representative Andrew Murr, and our State Senators Dawn Buckingham and Pete Flores -- all who wrote letters on our behalf, doubting the wisdom of granting a permit to dump treated wastewater into a pristine creek. .
' WE WANT OUR ELECTED OFFICIALS TO REMAIN ENGAGED AND WE ARE ASKING THEM TO ATTEND THE AGENDA MEETING WHERE THEY CAN SPEAK ON OUR BEHALF.
This means that our voice can still be heard, on a different level.
A VERY POWERFUL LEVEL.
OUR ELECTED OFFICIALS represent all of us.
State Representative Andrew Murr
715 Water Street
Kerrville, TX 78028
State Senator Dawn Buckingham
819 Water Street
Suite 125
Kerrville, TX 78028
State Senator Pete Flores
P.O. Box 4100
Del Rio, Texas 78841-4100
The public comment period has ended but our voice can be heard through comments from our elected officials. Will you please take a few minutes to drop a comment in the mail to one or more of the officials listed above. You don't have to live in their district to comment - your voice will not only count but if you are outside the district and still in Texas, your comment will be shared 'across the aisle' between representatives and senators to bridge efforts for joining forces to protect the Texas Hill Country pristine waters.
here is a sample of a letter - make yours personal.
I am writing to request you make an official statement to the Texas Commission on Environmental Quality (TCEQ) in support of FRIENDS HONDO CANYON for the denial of a pending Texas Pollutant Discharge Elimination System (TPDES), permit # WQ0015713001 in Tarpley Texas. Here are three reasons why this permit should be denied:
3. It is not an economic hardship to change to a zero-discharge permit (either septic or Texas Land Application). There are 81 similar youth camps in the Texas Hill Country, and all but one uses a zero-discharge method. These camps remain profitable.
2. Join our Neighborhood! Join FRIENDS OF Hondo Canyon. We need your financial support to successfully navigate this next legal step in the TCEQ protest process.
dues are $10/year. All donations above this amount go towards our cause. You can donate on line (Fundly charges 10% fee for this), donate by check (no fee charged by bank). We are a 501(c)3 organization and I will send you a tax receipt. Mail checks to:
Margo Denke Griffin
Secretary Treasurer
Friends of Hondo Canyon
11035 FM 470
Tarpley, TX 78883
1. WRITE THE ELECTED OFFICIALS
We have letters from our State Representative Andrew Murr, and our State Senators Dawn Buckingham and Pete Flores -- all who wrote letters on our behalf, doubting the wisdom of granting a permit to dump treated wastewater into a pristine creek. .
' WE WANT OUR ELECTED OFFICIALS TO REMAIN ENGAGED AND WE ARE ASKING THEM TO ATTEND THE AGENDA MEETING WHERE THEY CAN SPEAK ON OUR BEHALF.
This means that our voice can still be heard, on a different level.
A VERY POWERFUL LEVEL.
OUR ELECTED OFFICIALS represent all of us.
State Representative Andrew Murr
715 Water Street
Kerrville, TX 78028
State Senator Dawn Buckingham
819 Water Street
Suite 125
Kerrville, TX 78028
State Senator Pete Flores
P.O. Box 4100
Del Rio, Texas 78841-4100
The public comment period has ended but our voice can be heard through comments from our elected officials. Will you please take a few minutes to drop a comment in the mail to one or more of the officials listed above. You don't have to live in their district to comment - your voice will not only count but if you are outside the district and still in Texas, your comment will be shared 'across the aisle' between representatives and senators to bridge efforts for joining forces to protect the Texas Hill Country pristine waters.
here is a sample of a letter - make yours personal.
I am writing to request you make an official statement to the Texas Commission on Environmental Quality (TCEQ) in support of FRIENDS HONDO CANYON for the denial of a pending Texas Pollutant Discharge Elimination System (TPDES), permit # WQ0015713001 in Tarpley Texas. Here are three reasons why this permit should be denied:
- NO ONE WHO LIVES HERE wants this discharge permit to be approved. All seven counties in the Upper Nueces River Basin have passed resolutions (copies enclosed) in their respective County Commissioner’s Courts to support legislation to prevent TCEQ from accepting applications for direct discharge of pollutants in this sensitive area.
3. It is not an economic hardship to change to a zero-discharge permit (either septic or Texas Land Application). There are 81 similar youth camps in the Texas Hill Country, and all but one uses a zero-discharge method. These camps remain profitable.
2. Join our Neighborhood! Join FRIENDS OF Hondo Canyon. We need your financial support to successfully navigate this next legal step in the TCEQ protest process.
dues are $10/year. All donations above this amount go towards our cause. You can donate on line (Fundly charges 10% fee for this), donate by check (no fee charged by bank). We are a 501(c)3 organization and I will send you a tax receipt. Mail checks to:
Margo Denke Griffin
Secretary Treasurer
Friends of Hondo Canyon
11035 FM 470
Tarpley, TX 78883
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Other environmental organizations are fighting similar battles. However, The Friends of Hondo Canyon have a chance to make a WIN-WIN for WATER because we are simply requesting that the Torns apply for a zero discharge permit instead of a permit that allows them to dump waste in the creek. We do not mind having the camp as our neighbors we just want them to respect the health of our creek and the livlihood of their neighbors by using a zero discharge permit instead! The Friends of Hondo Canyon have done everything we can to protest this permit. We have written letters to the Torns, asking them to please consider their neighbors by retracting the permit and applying for a Zero Waste Permit instead.
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We have written letters to the TCEQ, expressing our grievances against the proposed permit. We have submitted over 350 comments online to TCEQ asking them to deny this permit. Our chance for individual comments ended with the public meeting, but we can still comment through our elected officials, who represent us. Our next step entails having expert legal support to represent us at the SOAH hearing sheduled for September 28, 2020. We have hired an environmental lawyer to represent our nonprofit organization. Can you join in?. Please donate to our campaign, and help us keep Commissioners and Hondo Creek PRISTINE.
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